https://www.taxtmi.com/acts?id=5960 Article 5 defines permanent establishment as a fixed place of business including management, branch, office, factory, workshop, extraction sites, farms, warehouses, and construction or assembly projects; it also covers furnishing services through personnel when activities continue for a specified duration. Exclusions cover preparatory or auxiliary activities and sole storage or processing stocks. A dependent agent who habitually concludes contracts, holds stock for regular delivery, or secures orders substantially for the enterprise creates a permanent establishment, whereas independent brokers acting in the ordinary course do not. Related-company control alone does not create a permanent establishment, and insurance enterprises collecting premiums or insuring risks via employees or non-independent representatives are treated as having one. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 04 Mar 2009 16:23:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5960 Article 5 defines permanent establishment as a fixed place of business including management, branch, office, factory, workshop, extraction sites, farms, warehouses, and construction or assembly projects; it also covers furnishing services through personnel when activities continue for a specified duration. Exclusions cover preparatory or auxiliary activities and sole storage or processing stocks. A dependent agent who habitually concludes contracts, holds stock for regular delivery, or secures orders substantially for the enterprise creates a permanent establishment, whereas independent brokers acting in the ordinary course do not. Related-company control alone does not create a permanent establishment, and insurance enterprises collecting premiums or insuring risks via employees or non-independent representatives are treated as having one. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5960